The FAA has recently made a proposal to require reduced time-in-service for TITAN® brand 520/550 cylinder assemblies produced between 2000 and 2009, based on Service Difficulty Reports (SDR) of some 30 cylinders.
ECi is challenging the proposal and working to have it modified, as ECi has engineering data and analysis showing the root cause of the failures being related to over-temperature and similar operating conditions.
We believe these conditions are at the core of these 30 incidents, and also the probable root cause of more than 1200 similar cylinder incidents related to other manufacturers.
Voice Your Comments to the FAA
On March 12, the Federal Aviation Administration (FAA) announced the availability of and request for comment on the Initial Regulatory Flexibility Act (IRFA) for the previously published proposed airworthiness directive (AD) that requires early removal of cylinder assemblies manufactured by Airmotive Engineering Corp. and sold by Engine Components, Inc. for installation on Continental IO/TSIO-520 and 550 engines (FAA-2012-0002).
The FAA published the IRFA in response to industry comments that the agency hadn’t conducted an adequate or accurate analysis to assess the economic impact on small businesses. Unfortunately, the “new” analysis still does not meet the description of a “complete IRFA” under the Regulatory Flexibility Act. Further, the FAA continues to significantly underestimate the cost of compliance; industry calculations suggest that the proposed AD will generate over $100 million in compliance costs, triggering congressional review under the Congressional Review Act.
We urge all impacted parties to provide detailed and substantive comments (particularly regarding the proposal’s economic impact) to the reopened docket prior to closing on May 12.
It is impossible to respond to, and accurately submit a comment on unpublished, unsubstantiated data. Unfortunately, the FAA has not provided any data in support of its proposal. The only information available on which to comment is the general statement, "numerous Cracks...". Therefore the most effective comments to the FAA will address the issue of cracking directly, by providing evidence of the scope and prevalence of cracking throughout cylinders of all manufactures.
Many people mistakenly believe that their comment (technically called a "Public Submission") or letter posted on the NPRM/docket constitutes a “vote” regarding the issues concerning them.
Although public support or opposition may help guide important public policies, agencies make determinations for a proposed action based on sound reasoning and documented evidence, not a majority of votes. A single, well-supported comment may carry more weight than a thousand form letters.
Follow this link for answers to these and other questions...
FAA Issues Proposed AD that will Cost Aircraft Owners $83 Million
Webpage | PDF
FAA Declares War Against ECi Cylinders
AOPA Article | Letter to the FAA: Signed by AOPA, ABS, Cessna Pilots Association, EAA, NATA, Savvy AMM, Twin Cessna Flyers
Letter of Request: Withdraw or
A Letter to the General Aviation Community from RAM Aircraft, LP
Ownership Hassle vs. an AD
Technical Articles: Raising Pilot Awareness
Cracked: What does a cylinder crack look like?